Deposition Cross-Notice Template

[Attorney Name or Party Name]
[Law Firm Name, if applicable]
[Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]

IN THE [NAME OF COURT]
FOR [COUNTY / DISTRICT / JURISDICTION]

[Plaintiff / Petitioner Name],
Plaintiff / Petitioner,

v.
[Defendant / Respondent Name],
Defendant / Respondent.

Case No.: [Case Number]

1. Title of Notice

DEPOSITION CROSS-NOTICE

PLEASE TAKE NOTICE that [Name of Party] hereby cross-notices the deposition identified below and intends to examine the deponent at that deposition, subject to applicable rules, objections, and any court order.

2. Party Giving Cross-Notice

Cross-Noticing Party: [Party Name]

Counsel for Cross-Noticing Party, if applicable:

[Attorney Name]
[Law Firm Name]
[Address]
[Phone Number]
[Email Address]

3. Previously Noticed Deposition

This Cross-Notice relates to the deposition previously noticed by:

[Name of Noticing Party]

Original Notice Date: [Date]

Deponent Name: [Full Name]

Date of Deposition: [Date]
Time of Deposition: [Time]
Location of Deposition: [Address / Remote Platform / Other]

4. Cross-Notice Statement

The Cross-Noticing Party hereby gives notice that it also notices the deposition of [Deponent Name] on the date, time, and location stated above.

The Cross-Noticing Party reserves the right to attend, question the deponent, make a record, and otherwise participate in the deposition as permitted by applicable rule and court order.

5. Method of Recording

The deposition is expected to be recorded by:

☐ stenographic means
☐ audio recording
☐ audiovisual recording
☐ remote audiovisual platform
☐ other: [Describe]

If the Cross-Noticing Party designates an additional method of recording, that method is:

[Describe additional method, if any]

6. Remote Appearance, if Applicable

If the deposition will proceed by remote means, the following details apply:

Remote Platform: [Platform Name]
Meeting Link or Access Information: [Insert details]
Technical Contact: [Name / Email / Phone Number]

Additional remote appearance instructions, if any:

[Insert details]

7. Documents or Things Requested

The Cross-Noticing Party requests that the deponent bring or produce the following documents, electronically stored information, or tangible things at the deposition, if applicable:

[Describe requested documents]
[Describe requested documents]
[Describe requested documents]

If this request is made by separate subpoena, request for production, or attached schedule, identify it here:

[Insert details]

8. Scope of Examination

The Cross-Noticing Party expects to examine the deponent regarding the following subject areas, if applicable:

[Subject area]
[Subject area]
[Subject area]

Additional examination topics, if any:

[Insert details]

9. Reservations

This Cross-Notice is made without waiving any objection, privilege, or other right available under applicable law or rule.

The Cross-Noticing Party also reserves the right to:

☐ proceed with examination even if another party limits or withdraws questioning
☐ adjourn or continue the deposition if permitted
☐ seek further relief from the court if needed
☐ other: [Describe]

10. Coordination and Scheduling Notes

Counsel and parties are requested to coordinate any scheduling, platform, interpreter, exhibit, or document-handling issues in advance of the deposition.

Additional coordination notes, if any:

[Insert details]

11. Signature

Dated: [Date]

Signature: __________________________
Name: [Attorney Name or Party Name]
Title: [Attorney for Party / Self-Represented Party / Other]
Bar Number: [Bar Number, if applicable]

12. Certificate of Service

I certify that on [Date], I served this Deposition Cross-Notice on the following person(s) or party(ies):

[Name] – [Address / Email]
[Name] – [Address / Email]

Method of Service:

☐ email
☐ electronic filing system
☐ mail
☐ hand delivery
☐ other: [Specify]

Signature: __________________________
Name: [Attorney Name or Party Name]
Date: [Date]